Plaintiff, the Federal Trade Commission ("FTC" or "Commission"), has filed a complaint
for a permanent injunction and other equitable relief in this matter, pursuant to Section 13(b) of
the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. §§ 53(b), charging defendant
Jacqueline Sabal with violations of Sections 5 and 12 of the FTC Act, 15 U.S.C. §§ 45 and 52.
The Commission, by and through its counsel, and defendant Jacqueline Sabal have agreed to the
entry of this Stipulated Order for Permanent Injunction and Final Judgment by this Court in order
to resolve all matters of dispute between them in this action without trial or adjudication of any
issue of law or fact herein.

NOW, THEREFORE, defendant Jacqueline Sabal and the Commission have requested the
Court to enter this Stipulated Order for Permanent Injunction and Final Judgment. It is therefore
ORDERED, ADJUDGED AND DECREED as follows:

FINDINGS

1. This Court has jurisdiction over the subject matter of this case and all parties
hereto.

2. The Complaint states a claim upon which relief may be granted against defendant
Jacqueline Sabal under Sections 5, 12, and 13(b) of the FTC Act, 15 U.S.C. §§ 45, 52, and 53(b).

3. On January 12, 1998, plaintiff filed its Complaint for a permanent injunction and
other equitable relief in this matter, pursuant to Section 13(b) of the FTC Act, 15 U.S.C. § 53(b).

4. On July 20, 1998, this Court entered an order granting the FTC's Motion for a
Preliminary Injunction Order and Asset Freeze against defendant Jacqueline Sable.

5. Defendant Jacqueline Sabal has waived all claims under the Equal Access to
Justice Act, 28 U.S.C. § 2412, and all rights to seek judicial review or otherwise to challenge the
validity of this Stipulated Order for Permanent Injunction and Final Judgment.

6. Entry of this Order is in the public interest.

7. This Stipulated Order for Permanent Injunction and Final Judgment does not
constitute and shall not be interpreted to constitute either an admission by the defendant or a
finding by the Court that defendant has engaged in violations of the FTC Act.

DEFINITIONS

For purposes of this Stipulated Order for Permanent Injunction and Final Judgment, the
following definitions shall apply:

1. "Defendant" means Jacqueline Sabal, individually, and her successors and assigns,
officers, directors, agents, representatives, employees, and those persons in active concert with
her, who receive actual notice of this Order by personal service or otherwise, whether acting
directly or through any entity, corporation, subsidiary, division, or other device.

2. "Competent and reliable scientific evidence" shall mean tests, analyses, research,
studies, or other evidence based on the expertise of professionals in the relevant area, that has
been conducted and evaluated in an objective manner by persons qualified to do so, using
procedures generally accepted in the profession to yield accurate and reliable results.

4. "Business opportunity" or "Business venture" means any written or oral business
arrangement, however denominated, whether or not covered by the Franchise Rule, which
consists of the payment of any consideration for: (a) the right or means to offer, sell, or distribute
goods or services (whether or not identified by a trademark, service mark, trade name,
advertising, or other commercial symbol); and (b) more than nominal assistance to any person or
entity in connection with, or incident to, the establishment, maintenance, or operation of a new
business or the entry by an existing business into a new line or type of business.

ORDER

I.

BANNED FROM SELLING OR ASSISTING IN THE SALE OF ANY

HAIR GROWER OR HAIR LOSS PREVENTION PRODUCT

IT IS THEREFORE ORDERED that defendant, Jacqueline Sabal, directly or through
any corporation, subsidiary, division, or other device, is hereby permanently restrained and
enjoined from engaging or participating in the manufacturing, labeling, advertising, promoting,
marketing, offering for sale, sale or distribution of any product or service which she, or any
person or entity acting in concert or participation with her, claims will result in hair growth
anywhere on the body, hair loss prevention, or the treatment or prevention of baldness.

II.

MISREPRESENTATIONS AND VIOLATIONS OF SECTION 5

IT IS FURTHER ORDERED that defendant, directly or through any corporation,
subsidiary, division, or other device, in connection with the manufacturing, labeling, advertising,
promoting, marketing, offering for sale, sale, or distribution of Sable Hair Farming System or Hair
Farming, or any product that is substantially similar in ingredients, composition and properties, is
hereby permanently restrained and enjoined from representing, in any manner, expressly or by
implication, that:

C. Such product will promote the growth of hair anywhere on the body where hair
has already been lost;

D. Such product is superior to Rogaine and Minoxidil in stopping, preventing, curing,
relieving, reversing or reducing hair loss;

unless, at the time the representation is made, defendant possesses and relies upon competent and
reliable scientific evidence that substantiates the representation.

III.

PROHIBITED BUSINESS ACTIVITIES

IT IS FURTHER ORDERED that defendant, directly or through any corporation,
subsidiary, division, or other device, in connection with the manufacturing, labeling, advertising,
promoting, marketing, offering for sale, sale, or distribution of any product or service, is hereby
permanently restrained and enjoined from:

A. Misrepresenting, directly or by implication, or failing to disclose any fact material
to a consumer's decision to purchase or use said product or service;

B. Misrepresenting, directly or by implication, the existence, contents, validity,
results, conclusions or interpretations of any test, study, or research;

C. Misrepresenting, directly or by implication, the benefits, performance, or efficacy
of any product or service;

D. Misrepresenting, directly or by implication, that the experience of any purchaser
represented in a testimonial or endorsement represents the typical or ordinary
experience of consumers unless:

1. The representation is true, and at the time it is made, defendant possesses
and relies upon competent and reliable evidence, which when appropriate
must be competent and reliable scientific evidence, that substantiates the
representation;

2. Defendant discloses, clearly and prominently, and in close proximity to the
endorsement or testimonial, either:

a. What the generally expected results would be for users of the
product or service; or

b. The limited applicability of the endorser's experience to what
consumers may generally expect to achieve, that is, that consumers
should not expect to experience similar results.

Nothing contrary to, inconsistent with, or in mitigation of the disclosure
shall be used in any advertisement or on any label. For purposes of this
Part, "endorsement" shall mean as defined in 16 C.F.R. § 255.0(b), a copy
of which is attached hereto as Attachment 1;

E. Making any representation, expressly or by implication, that does not comply with
any applicable rule or regulation established by the Food and Drug Administration;

F. Violating any provision of the Telemarketing Sales Rule, 16 C.F.R. Part 310, a
copy of which is attached hereto as Attachment 2; and

G. Conducting or participating in any telemarketing solicitation without compliance
with all applicable federal and state registration and bond requirements.

IV.

OTHER PROHIBITED BUSINESS PRACTICES

IT IS FURTHER ORDERED that defendant, directly or through any corporation,
subsidiary, division, or other device, in connection with the advertising, marketing, proposed sale,
or sale of any franchise or business venture, or the entering into any contract or any other arrangement relating to the advertising, marketing, proposed sale or sale of any franchise or
business venture, is hereby permanently restrained and enjoined from:

A. Making or assisting in the making of, expressly or by implication, any statement or
representation of material fact, orally or in writing, that is false or misleading,
including, but not limited to the following:

1. The income, profits, or sales volume capable of being achieved by
franchise or business venture purchasers;

2. The income, profits, or sales volume achieved by other franchise or
business venture purchasers;

3. The risk, liquidity, market value, resale value, or expected income or profit
of any product or service sold in connection with any business opportunity;

B. Violating or assisting others to violate any provision of the Commission's
Franchise Rule, 16 C.F.R. Part 436, a copy of which is attached hereto as
Attachment 3 and incorporated by reference, including, but not limited to:

1. Failing to provide potential franchisees with a complete and accurate
disclosure document in the manner and within the time frame required by
the Rule, 16 C.F.R. § 436.1(a);

2. Failing to provide potential franchisees with an earnings claim document
when any earnings claim is made, as required by the Rule, 16 C.F.R.
§ 436.1(b) - (e);

3. Failing to disclose, in immediate conjunction with any mass advertised
earnings claim, the material basis for the claim (or lack of such basis) and a
warning that the earnings claim is only an estimate, as required by the Rule,
16 C.F.R. § 436.1(e)(3) - (4).

V.

RIGHT TO REOPEN

IT IS FURTHER ORDERED that within ten (10) business days after the date of entry
of this Stipulated Order by the Court defendant Jacqueline Sabal shall submit to the Commission a
truthful sworn statement in the form shown on Attachment 4 of this Stipulated Order that shall
reaffirm and attest to the truthfulness, accuracy and completeness of the financial statement signed
by the defendant on August 22, 1998. The Commission's agreement to this Stipulated Order is
expressly premised upon the financial condition of defendant Jacqueline Sable as represented in
the financial statement referenced above, which contain material information upon which the
Commission relied in negotiating and agreeing upon this Stipulated Order for Permanent
Injunction and Final Judgment. If, upon motion by the Commission, this Court finds that
defendant Jacqueline Sable failed to file the sworn statement required by this section, or filed a
statement that failed to disclose any material asset, or materially misrepresented the value of any
asset, or made any other material misrepresentation in or omission from her financial statement,
the Commission may request that the judgment herein be reopened for the purpose of requiring
monetary consumer redress or obtaining other equitable relief; provided, however, that in all other
respects this judgment shall remain in full force and effect, unless otherwise ordered by this Court;
and provided further, that proceedings instituted under this section are in addition to and not in
lieu of any other civil or criminal remedies as may be provided by law, including, but not limited
to, contempt proceedings, or any other proceedings the Commission may initiate to enforce this
Stipulated Order for Permanent Injunction and Final Judgment.

VI.

ACKNOWLEDGMENT OF RECEIPT OF ORDER

IT IS FURTHER ORDERED that, within ten (10) business days after receipt by
defendant of this Order as entered by the Court, defendant shall submit to the Commission a
truthful sworn statement, in the form shown on Attachment 5, that shall acknowledge receipt of
this Final Order.

VII.

PROVIDE COPY OF ORDER

IT IS FURTHER ORDERED that defendant, her successors and assigns, shall
immediately upon entry of this Order, and for a period of five (5) years from the date of the entry
of this Order:

A. Provide a copy of this Order to, and obtain a signed and dated acknowledgment of
receipt of this Order from, each of her current and future officers, directors,
agents, representatives, servants, employees, salespersons, independent
contractors, and telemarketers who are engaged in the manufacturing, labeling,
advertising, promotion, marketing, offering for sale, sale or distribution of any
food, drug, or cosmetic as "food," "drug," and "cosmetic" are defined in Section
15 of the Federal Trade Commission Act, 15 U.S. C. § 55, or any dietary
supplement, or any franchise or business opportunity;

B. Maintain, and upon reasonable notice make available to representatives of the
Commission, the original and dated acknowledgments of receipts of copies of this
Order required by Paragraph A above, and a list identifying the names, addresses,
and telephone numbers of the persons or entities served with a copy of this Order.

VIII.

MAINTAIN RECORDS

IT IS FURTHER ORDERED that defendant, and her officers, agents, directors, servants, employees, salespersons, independent contractors, attorneys, corporations, subsidiaries,
affiliates, successors, assigns, all other persons or entities directly or indirectly under her control
or under common control with her, and all other persons in active concert or participation with
her, who receive actual notice of this Order by personal service or otherwise, whether acting directly or through any trust, corporation, subsidiary, division, or other device, are hereby enjoined
from:

A. Failing to make and keep books, records, accounts, bank statements, current
accountants' reports, general ledgers, general journals, cash receipt ledgers and
source documents, documents indicating title to real or personal property, and any
other data which, in reasonable detail, accurately and fairly reflect the transactions
and dispositions of the assets of defendant; and

IT IS FURTHER ORDERED that, for a period of five (5) years from the date of entry
of this Order, defendant, her successors and assigns, agents, employees, officers, and servants,
corporations, and those persons in active concert or participation with her, who receive actual
notice of this Order by personal service or otherwise, in connection with any business where
defendant is the majority owner of the business or directly or indirectly manages or controls the
business, and where the business engages in the manufacturing, labeling, advertising, promoting,
marketing, offering for sale, sale, or distribution of any food, drug, or cosmetic, as defined by
Section 15 of the Federal Trade Commission Act, 15 U.S.C. § 55, or any dietary supplement, or
any franchise or business opportunity, is hereby permanently restrained and enjoined from failing
to create, and from failing to retain for a period of three (3) years following the date of such
creation, unless otherwise specified:

A. Books, records and accounts that, in reasonable detail, accurately and fairly reflect
the cost of goods or services sold, revenues generated, and the disbursement of
such revenues;

B. Records accurately reflecting: the name, address, and telephone number of each
person employed in any capacity by such business, including as an independent
contractor; that person's job title or position; the date upon which the person
commenced work; and the date and reason for the person's termination, if
applicable. The businesses subject to this Paragraph shall retain such records for
any terminated employee for a period of two (2) years following the date of
termination;

C. Records containing the names, addresses, phone numbers, dollar amounts paid,
quantity of items or services purchased, and description of items or services
purchased, for all consumers to whom such business has sold, invoiced or shipped
any goods or services;

D. Records that reflect, for every consumer complaint or refund request, whether
received directly or indirectly or through any third party:

1. The consumer's name, address, telephone number and the dollar amount
paid by the consumer;

2. The written complaint or refund request, if any, and the date of the
complaint or refund request;

3. The basis of the complaint, including the name of any salesperson
complained against, and the nature and result of any investigation
conducted concerning any complaint;

4. Each response and the date of response;

5. Any final resolution and the date of the resolution;

6. In the event of a denial of a refund request, the reason for the denial;

E. Copies of all sales scripts, training materials, advertisements, or other marketing
materials utilized; provided that copies of all sales scripts, training materials,
advertisements, or other marketing materials utilized shall be retained for three (3)
years after the last date of dissemination of any such materials;

F. Copies of all materials relied upon in disseminating any representations covered by
this Order, and all tests, reports, studies, surveys, demonstrations, or other
evidence in defendant's possession and control that contradict, qualify, or call into
question the representations made, or the basis relied upon for the representation,
including complaints and other communications with consumers or with
governmental or consumer protection organizations shall be retained for five (5)
years after the last date of dissemination of any such representation.

X.

COMPLIANCE REPORTING BY DEFENDANT

IT IS FURTHER ORDERED that, in order that compliance with the provisions of this
permanent injunction may be monitored:

A. For a period of five (5) years from the date of entry of this Order, defendant shall
notify the Commission of the following:

1. Any changes in defendant's residence, mailing address, and telephone
number, within ten (10) days of the date of such change;

2. Any changes in defendant's employment status (including self-employment)
within ten (10) days of such change. Such notice shall include the name
and address of each business that defendant is affiliated with or employed
by, a statement of the nature of the business, and a statement of
defendant's duties and responsibilities in connection with the business or
employment;

3. Any proposed change in the structure of any business entity owned or
controlled by defendant, such as creation, incorporation, dissolution,
assignment, sale, merger, dissolution of subsidiaries, proposed filing of a
bankruptcy petition, or change in the corporate name or address, or any
other change that may affect compliance obligations arising out of this
Order, thirty (30) days prior to the effective date of any proposed change;
provided, however, that, with respect to any proposed change in the
corporation about which defendant learns less than thirty (30) days prior to
the date such action is to take place, defendant shall notify the Commission
as soon as is practicable after learning of such proposed change;

B. One hundred eighty (180) days after the date of entry of this Order, defendant shall
provide a written report to the FTC, sworn to under penalty of perjury, setting
forth in detail the manner and form in which the defendant has complied and is
complying with this Order. This report shall include but not be limited to:

1. Defendant's then current residence address and telephone number;

2. Defendant's then current employment, business address and telephone
numbers, a description of the business activities of each such employer, and
defendant's title and responsibilities for each employer;

3. A copy of each acknowledgment of receipt of this Order obtained by
defendant pursuant to Paragraph VII;

4. A statement describing the manner in which defendant has complied and is
complying with the terms of this Order;

C. Upon written request by a representative of the Commission, defendant shall
submit additional written reports, sworn to under penalty of perjury, and produce
documents on fifteen (15) days notice with respect to any conduct subject to this
Order;

D. For the purposes of this Order, defendant shall, unless otherwise directed by the
Commission's authorized representatives, mail all written notifications and reports
to the Commission to:

Regional Director

Federal Trade Commission

55 East Monroe Street, Suite 1860

Chicago, IL 60603

Re: FTC v. Jacqueline Sabal

98 C 0170

E. For the purposes of this Paragraph, "employment" includes the performance of
services as an employee, consultant, or independent contractor; and "employers"
include any individual or entity for whom defendant performs services as an
employee, consultant, or independent contractor;

F. For purposes of the compliance reporting required by this Paragraph, the
Commission is authorized to communicate directly with defendant.

XI.

COMMISSION'S AUTHORITY TO MONITOR COMPLIANCE

IT IS FURTHER ORDERED that the Commission is authorized to monitor defendant
Jacqueline Sabal's compliance with this Order by all lawful means, including but not limited to the
following means:

A. The Commission is authorized, without further leave of court, to obtain discovery
from any person in the manner provided by Chapter V of the Federal Rules of Civil
Procedure, Fed. R. Civ. P. 26-37, including the use of compulsory process
pursuant Rule 45 of the Federal Rules of Civil Procedure, for the purpose of
monitoring and investigating defendant's compliance with any provision of this
Order;

B. The Commission is authorized to use representatives posing as consumers and
suppliers to defendant, defendant's employees, or any other entity managed or
controlled in whole or in part by defendant, without the necessity of identification
or prior notice;

C. Nothing in this Order shall limit the Commission's lawful use of compulsory
process, pursuant to Sections 9 and 20 of the FTC Act, 15 U.S.C. § § 49, and 57b-1, to investigate whether defendant has violated any provision of this Order or
Section 5 of the FTC Act, 15 U.S.C. § 45.

XII.

ACCESS TO BUSINESS PREMISES

IT IS FURTHER ORDERED that for a period of five (5) years from the date of entry of
this Order, for the purpose of further determining compliance with this Order defendant shall
permit representatives of the Commission, within three (3) business days of receipt of written
notice from the Commission:

A. Access during normal business hours to any office, or facility storing documents,
of any business where;

1. Defendant is the majority owner of the business or directly or indirectly
manages or controls the business, and where;

2. The business is engaged in the manufacturing, labeling, advertising,
promoting, marketing, offering for sale, or sale of any food, drug, or
cosmetic as defined by Section 15 of the Federal Trade Commission Act,
15 U.S.C. § 55, or any dietary supplement, or any franchise or business
opportunity;

In providing such access defendant shall permit representatives of the Commission
to inspect and copy all documents relevant to any matter contained in this Order;
and shall permit Commission representatives to remove documents relevant to any
matter contained in this Order for a period not to exceed ten (10) business days so
that the documents may be inspected, inventoried, and copied;

B. To interview the officers, directors, and employees, including all personnel
involved in responding to consumer complaints or inquiries, and all sales
personnel, whether designated as employees, consultants, independent contractors
or otherwise, of any business to which Subsection A of this Paragraph applies,
concerning matters relating to compliance with the terms of this Order. The
person interviewed may have counsel present.

Provided that, upon application of the Commission and for good cause shown, the Court
may enter an ex parte order granting immediate access to defendant's business premises for the
purposes of inspecting and copying all documents relevant to any matter contained in this Order.

XIII.

CONSUMER REPORTING AGENCIES

IT IS FURTHER ORDERED that, pursuant to Section 604 of the Fair Credit Reporting
Act, 15 U.S.C. § 1681(b), any consumer reporting agency may furnish a consumer or credit
report concerning defendant to plaintiff.

XIV.

ASSET FREEZE LIFTED

IT IS FURTHER ORDERED that the freeze of the assets of defendant Jacqueline Sabal
obtained by the Commission, in any bank account or savings and loan institution, wherever
located, shall be lifted upon the entry of this Order by the Court.

XV.

COSTS AND ATTORNEY'S FEES

IT IS FURTHER ORDERED that each party shall bear its own costs and attorney's
fees.

XVI.

RETENTION OF JURISDICTION

IT IS FURTHER ORDERED that this Court retains jurisdiction of this matter for the
purpose of enabling the parties to apply to the Court at any time for such further orders or
directives as may be necessary or appropriate for the interpretation or modification of this
Judgment, for the enforcement or compliance therewith, or the punishment of violations thereof.

The parties agree and stipulate to entry of the foregoing Order for Permanent Injunction

and Final Judgment.

For the FEDERAL TRADE COMMISSION DEFENDANT

_______________________________ ___________________________________

THERESA M. McGREW JACQUELINE SABAL

RUSSELL W. DAMTOFT (a.k.a. JACQUELINE SABLE)

Attorneys for Plaintiff

Federal Trade Commission

55 East Monroe, Suite 1860 ___________________________________

Chicago, IL 60603 STUART W. OPDYCKE

(312) 960-5634 Attorney for Defendant

53 West Jackson, Suite 224

Chicago, IL 60604

(312) 986-0898

SO ORDERED, this _____day of _______________________, 1998, at ______.